Investment Advisers

SEC3 offers an extensive suite of customizable compliance services for investment advisers, on either a one-time or recurring basis depending on your needs.

Examples of potential services include, but are not limited to:

  • Annual Compliance Reviews
  • Quarterly Compliance Reviews
  • Due Diligence Reviews
  • Risk Assessment and Gap Analysis
  • Compliance Testing and Analysis
  • Mock SEC Examinations
  • Compliance Training
  • Customized Compliance Services

Annual Compliance Review

For registered advisers, the Compliance Rule requires each adviser to review its policies and procedures, at least annually, to determine their adequacy and the effectiveness of their implementation. In Annual Compliance Review services, SEC3 can assist Chief Compliance Officers in every phase of the annual review process, from formulating a strategic plan, to conducting thorough assessments and testing of all aspects of the compliance program, to planning for next year's review. SEC3's Annual Compliance Review allows advisers to maximize available resources by fulfilling specific elements or the entire scope of the regulatory obligation. The Annual Compliance Review can conclude with a customizable, easy to read report and action plan.

Quarterly Compliance Reviews

Most advisers would prefer to diversify the strain on operational and financial resources of an annual review over the course of the year, which is why SEC3 offers its flagship service, the Quarterly Compliance Review, as the perfect solution. Quarterly Compliance Reviews conduct all the aspects of the annual review over the course of the year in manageable phases while revisiting critical and changing areas throughout the year. The dynamic scope and disciplined approach of Quarterly Compliance Reviews stimulates the evolution of the compliance program, keeping it continually current and addressing any issues as they appear. Quarterly Compliance Reviews optimize compliance resources and limit the interruption of your firm. Like the Annual Compliance Review, each Quarterly Compliance Review can conclude with a customizable, easy to read report and action plan.

Additionally, Quarterly Compliance Reviews address the essential, on-going demands of a compliance program, such as managing disclosure documents, filing requirements, and compliance policies and procedures. Quarterly Compliance Reviews provide the opportunity for SEC3's professionals to establish a deep partnership with each adviser and fund and actively participate in the compliance program.

Risk Assessment & Gap Analysis

The Risk Assessment & Gap Analysis not only fulfills regulatory expectations, it provides valuable insights into your risk profile and your exposure to those risks. SEC3's Risk Assessment & Gap Analysis is a system that considers the likelihood and impact of the compliance risk specific to each advisory firm or fund and assesses how well the existing controls mitigate those risks. The Risk Assessment & Gap Analysis report is a concise, but detailed summary in plain English that prioritizes risks by exposure, arming the Chief Compliance Officer and Independent Directors with the critical information to immediately implement an action plan.

Compliance Testing & Analysis

Forensic tests are the eyes and ears of the Chief Compliance Officer. Without rigorous, consistent forensic testing, a Chief Compliance Officer has no early warning systems. Various forensic tests are means to identify symptoms of potential compliance problems and can serve as confirmation that the compliance program is functioning properly. SEC3 can assist Chief Compliance Officers in designing and conducting a battery of rigorous and periodic forensic compliance tests as part of the continuous monitoring of the compliance program; including, but not limited to, trading and execution, portfolio compliance, code of ethics, account administration, and investment performance.

Mock SEC Examinations

Much of the fear surrounding a regulatory examination stems from the "unknown" element. A Mock SEC Examination is an effective process to gauge the types of exposures and concerns that an adviser or fund would face during a real regulatory examination. Mock SEC Examinations use current exam focuses, with proven exam approaches and methodologies, including interviews, reviews of policy and procedures, analysis, and testing, and conclude with a customizable summary of assessments, recommendations, and proposed solutions. SEC3's professionals, with years of experience as senior examiners with the Securities and Exchange Commission or as compliance professionals, provide expert insight and guidance. Mock SEC Examinations pierce the mystique of a regulatory examination and transform an often stressful experience into a valuable assessment process that allows a Chief Compliance Officer and the compliance staff to face a future regulatory examination with confidence and peace of mind.

Compliance Training

Drafting and adopting reasonable policies and procedures is only part of the successful implementation of a compliance program; effective compliance training is also essential. The success of a compliance program is predominately determined by the ability of the adviser's or fund's staff to consistently fulfill the goals and functions of the policies and procedures. SEC3's professionals will assist Chief Compliance Officers in developing and conducting customized training programs to your staff on the various aspects of your compliance program and their responsibilities under that program. Our belief is that training should rejuvenate the staff's awareness and sensitivity of compliance policies while reinforcing the importance of each person's role in the compliance program.

Other customized services include:

  • Development and Implementation of Customized Compliance Policies and Procedures
  • Compliance Calendar & Planning Assistance
  • SEC Examination and Inquiry Response
  • Deficiency Letter Response and Remedial Action Plans
  • Form ADV and IARD Filings and Reviews
  • Registration Assistance: State and Federal
  • Disclosure Reviews


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SEC Raises Awareness Surrounding CCO Outsourcing

Yesterday, the SEC indirectly affirmed that registered investment advisers and investment companies can outsource their CCO to an unaffiliated third party and satisfy their 206(4)-7(c) and 38(a)-1(a)(4) obligations. However, advisers... read more »

SEC Provides Clarity on When and How the Enforcement Division Goes After CCOs

Yesterday, Director of the Enforcement Division of the Securities and Exchange Commission, Andrew Ceresney was the keynote speaker at the National Society of Compliance Professionals National Conference in Maryland. His... read more »

The SEC Outdoes Itself Again Announcing A Record Year for Enforcement Action

The Securities and Exchange Commission announced on October 22, 2015 a comprehensive report describing the results of enforcement actions taken against advisers in fiscal year 2015, which ended in September.... read more »

The Hunt Continues: SEC Goes After Large Private Equity Firm for Undisclosed Fee…

On October 7, 2015, the SEC announced a large settlement with a private equity firm charged with failure to disclose. The SEC said that the firm failed to sufficiently disclose... read more »

Adviser Settles SEC Cyber Enforcement Action

The Securities and Exchange Commission announced on September 22, 2015 that an investment adviser has agreed to settle charges that it failed to establish the required cybersecurity policies and procedures... read more »

First Case Brought Under Distribution-in-Guise Initiative

On September 21, 2015, the Securities and Exchange Commission charged  an asset manager with improperly using mutual fund shareholder's assets to pay two unnamed brokerage firms to market and distribute... read more »



When: November 17, 2015 Where: Convene Midtown East | 730 Third Avenue | New York, NY 10017 Janaya Moscony, President, SEC Compliance Consultants, Inc. will be moderating a...


When: October 13, 2015 Where: Blank Rome LLP | The Chrysler Building | 405 Lexington Avenue | New York, NY 10174 22nd Floor Boardroom Thomas Westle and Janaya Moscony, along with...

The SEC's Examination Priorities: What Every Private Fund Managers Need to Know …

In this CLE course, a panel of thought leaders and professionals organized by The Knowledge Group will provide the audience with an overview of the latest and remarkable issues...

Greenwich CCO Compliance Roundtable

When: June 24th 2015 Where: The Belle Haven Club | 100 Harbor Drive, Greenwich CT 06830

Miami Compliance Roundtable

When: March 30th 2015 Where: Kaufman Rossin Fund Services | 2699 Bayshore Drive, Miami FL 33133

NSCP Canadian Conference

When: March 4th 2015 (8:00am-4:00pm) Where: St. Andrew’s Club & Conference Centre | 150 King Street West Toronto, Ontario M5H 1J9

Dallas CCO Compliance Roundtable

When: March 05, 2015 Where: The Crescent Club | 200 Crescent Court, 17th Floor, Dallas, TX 75201

Phila Compliance Outreach Seminar

When: December 17th 2014 Where: Drinker Biddle & Reath LLP | One Logan Square, Ste. 2000, Philadelphia, PA 19103

IA Compliance Fall Conference 2014

When: September 22th, 2014 Where: Loews Philadelphia Hotel

NYC CCO Compliance Roundtable

When: September 23rd 2014 Where: Blank Rome LLP, The Chrysler Building, 405 Lexington Avenue, 22nd Floor Board Room

GAIM Ops Ireland 2014

When: October 8-10th, 2014 Where: Powerscourt Hotel, Wicklow Ireland

Financial Services Roundtable Series

When: August 6th 2014 Where: Anchin Block & Anchin, 1375 Broadway, New York, NY, 23rd Floor

NYC CCO Compliance Roundtable

When: April 29th 2014 Where: Blank Rome LLP, The Chrysler Building, 405 Lexington Avenue, 22nd Floor Board Room

NSCP Dallas Regional Meeting

When: April 10, 2014 (8am-5pm) Where: Haynes and Boone, LLP 2323 Victory Avenue, Ste. 700 Dallas, TX 75219

GAIM Ops Cayman 2014

When: April 6-9th, 2014 Where: Ritz Carlton, Grand Cayman